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does the odometer add mileage while flat towing?

I know it's been asked before but I do not remember solid answer. Im looking at buying a new(er) XJ. The guy says the odometer has about 90k but its only been driven about 30k. So my question is does the odometer add mileagewhile flat towing? I know the speedo has a gear driven sensor and the gear is turning when the Jeep is moveing but its (electrical) sensor working without the key on?

My 2000 TJ manual states to flat tow with T-case in neutral and the manual transmission in gear. I believe this is to prevent the transmission from spinning due to viscous (sp??) coupling. I don't know if this is because it would not be lubricated properly or just cause added wear.

Thanks Dave, thats what I figured. And yes im sure I will be able to tell the difference of 30k and 90k by looking at it but I have not had the time to go get it and do that yet.

Everyone else..............The speedo gear drives from the output shaft of the t-case, therefore if the rear driveshaft is spinning so is the gear. So, it makes no difference if everything is in neutral or not.